Wakilii

In the matter of the Estate of the late Ssajjabi Abusolomu (Miscellaneous Application 47 of 2025)

High Court · [2025] UGHC 1343 · 2025 Application Granted AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
Application for renewal and extension of Letters of Administration and leave to file inventory and final account out of time
Decision
Application allowed; Letters of Administration extended for two years; leave granted to file inventory and final account out of time

Observed later treatment

No later-treatment classification is recorded for this judgment.

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Holding

The High Court granted the application to renew and extend Letters of Administration for two years from 3 December 2025, finding sufficient cause in the loss of the certificate of title by the lands office and the presence of squatters requiring settlement negotiations. The court also granted leave to file the inventory and final account out of time, directing the administrator to file an updated inventory within 30 days and a final account at the end of the two-year extension period.

Outcome

Application allowed; Letters of Administration extended for two years; leave granted to file inventory and final account out of time

Facts

The applicant, Nassolo Jane, was granted Letters of Administration for the estate of the late Ssajjabi Abusolomu on 25 November 2016 under Administration Cause No. 2043 of 2016. She was required to file an inventory within six months and a final account within one year. The Letters of Administration expired on 31 May 2025 by operation of law without these obligations being fulfilled. The applicant attributed the delay to two factors: first, the certificate of title submitted to the lands office was lost, and a special certificate was only issued in 2022; second, the estate land was occupied by squatters and bibanja holders claiming ownership, requiring lengthy negotiations. The applicant engaged the squatters and bibanja holders, transferred portions to some, and was in the process of obtaining titles for others. The beneficiaries signed a consent dated 10 November 2025 endorsing the extension.

Issues

  1. Whether the Letters of Administration of the estate of late Ssajjabi Abusolomu should be renewed.
  2. Whether the time within which to file the inventory and final account should be extended.

Orders

  • Letters of Administration of the Estate of Late Ssajjabi Abusolomu vide Administration Cause no. 2043/2016 granted to the applicant is hereby extended for a period of two years from 3rd December 2025.
  • The Applicant is granted leave to file an inventory and final account of the estate vide Administration Cause no. 2043/2016 out of time.
  • The applicant is hereby directed to file an updated inventory clearly showing: (a) The name of the deceased, date of death, Administration Cause Number, date of issuance of the Letters of Administration, Names of Administrator, date of submission of inventory; (b) Properties that formed part of the deceased's estate as at the date of death with certified documentary evidence; (c) Credits of the deceased (if any); (d) Debts of the deceased (if any); (e) List of beneficiaries of the deceased and their National IDs; (f) Proposed distribution of properties among the beneficiaries and justification; (g) For property already distributed, a list of properties distributed and to whom.
  • The said inventory shall be filed within a period of 30 days from the date of this ruling.
  • At the end of two years, the applicant shall file a final account in this court.
  • No order is made as to costs.

Rules and key headnotes

Succession & Estates — Letters of Administration — Renewal and Extension — Sufficient Cause
Under section 337(4) of the Succession Act as amended, the court may extend the duration of Letters of Administration for a reasonable period upon application by the administrator. Loss of a certificate of title by the lands office and the presence of squatters on estate land requiring settlement negotiations constitute sufficient cause for granting an extension.
Succession & Estates — Inventory and Account — Extension of Time — Sufficient Cause
Under section 273(1) of the Succession Act as amended, an administrator must file an inventory within six months and an account within one year from the grant. Where the administrator is unable to comply within the prescribed time due to circumstances beyond their control, the court has discretion to grant leave to file out of time upon application showing sufficient cause.
Succession & Estates — Extension of Time — Test for Sufficient Cause
In determining an application for extension of time, the court must consider: (a) whether the applicant has established sufficient reasons for the extension; (b) whether the applicant is guilty of dilatory conduct; and (c) whether any injustice will be caused if the application is not granted.

Legislation cited (8)

Cases cited (5)

  • In the Matter of Extension of Letters of Administration by Kasirye Saul and Kyabagaba Joseph (Miscellaneous Application No. 2231 of 2005)
  • Lubombola Anthony Fredrick Gonza v The Estate of the Late Lubombola Yosam (Miscellaneous Application No. 03 of 2025)
  • Caroline Atuhweire v Kayondo (Miscellaneous Application No. 3045 of 2025)
  • Hadijah Ndagire and Another v Muhammad Kasozi and Others (High Court Civil Suit No. 40 of 2014)
  • Molly Kyalikunda Turinawe and Others v Engineer Ephraim Turinawe and Another (Supreme Court Civil Appeal No. 27 of 2010)

Full judgment

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The original judgment as reported. Read the original PDF before relying on any passage.

In the matter of the Estate of the late Ssajjabi Abusolomu (Miscellaneous Application 47 of 2025) [2025] UGHC 1343 (4 December 2025)
Source: this page presents Wakilii’s issue analysis and metadata for a publicly reported Ugandan judgment. Any AI-generated summary is marked as such. Judgment text is sourced from the Uganda Legal Information Institute (ulii.org). Wakilii is not affiliated with ULII.